(129 days)
The Applied Tissue Technologies PWD™ Platform Wound Dressing is intended to be used in conjunction with the Invia Motion Negative Pressure Wound Therapy (NPWT) system and is indicated in patients who would benefit from a suction device (NPWT) as it creates an environment that may promote wound healing by removing excess wound exudate. The Applied Tissue Technologies Platform Wound Dressing is appropriate for use on the following wounds: exudating, chronic, acute, traumatic, sub-acute and dehisced wounds, partial-thickness burns, ulcers (such as: diabetic, pressure and venous insufficiencies), flaps and grafts.
The Applied Tissue Technologies PWD™ Platform Wound Dressing is a single use device. Its transparency permits the healthcare practitioner to observe the progress of the wound healing without removing the wound dressing. There is an access port to administer negative pressure wound therapy. The PWD is intended to be used for a maximum of 3 days. Therapy duration may be less than indicated if clinical practice or other factors require more frequent dressing changes. The PWD will be marketed in four different shapes and sizes, all having the same intended use.
The provided text describes a 510(k) premarket notification for the Applied Tissue Technologies PWD™ Platform Wound Dressing. This document asserts substantial equivalence to a predicate device, the Medela Ag Invia Foam Dressing Kit (K170088), rather than detailing an independent study to prove specific acceptance criteria for a new AI/ML device.
Therefore, many of the requested categories are not applicable to the information contained in this FDA submission. The document focuses on demonstrating that the new device is as safe and effective as a legally marketed predicate device through performance data and a comparison of technological characteristics.
Here's an breakdown based on the provided text, highlighting what is available and what is not:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state "acceptance criteria" in the sense of predefined thresholds for clinical performance metrics (e.g., sensitivity, specificity, or improvement in a specific clinical outcome). Instead, it relies on demonstrating that the device's technical performance characteristics are acceptable and comparable to a predicate device.
| Performance Metric | Acceptance Criteria (Implied by Comparison) | Reported Device Performance (PWD™ Platform Wound Dressing) |
|---|---|---|
| Device Vapor Transmission | Acceptable | Acceptable test results |
| Ability to Maintain Negative Pressure | Acceptable | Acceptable test results |
| Ability to Remove Exudate | Acceptable | Acceptable test results |
| Biocompatibility | According to ISO 10993 standard series | Acceptable test results |
| Maximum Duration of a single dressing | 72 Hours (Same as predicate) | 72 Hours |
| Negative Pressure to the wound surfacerequirements in mmHg | 125 mmHg (Predicate) | 80 mmHg (nominal) +/- 20mmHG to the wound surface. Noted as a nominal recommended setting, pump settings range from -40 to -175. This difference does not raise new questions of safety. |
| Multiple Shapes for Wound Sizes up to 400cc | 240 - 2700cc (Predicate) | 400cc (within the range of the predicate device) |
| Dressing Configuration | Similar to predicate (Clear polyurethane occlusive drape dressing with foam insert) | Clear polyurethane embossed occlusive drape with tubing. (Similar materials and configuration; embossed layer allows fluid transfer instead of foam, deemed not to raise new questions of safety) |
| Access Port | Same as predicate | For attachment to the negative pressure pump; for removal of fluids. |
| Collection Pack | Same as predicate | PWD tubing connected to Medela Invia Motion canister/tubing set for fluid collection. |
| Pump | Same as predicate | To be used with the Medela Invia® Motion™ Negative Pressure Wound Therapy System. |
| How Supplied | Same as predicate | Sterile Single Use Only |
| Tissue Contact Materials | Similar to predicate | Polymers and Adhesive (Differences do not introduce new questions of safety) |
| Additives - antimicrobial, animal origin | No (Same as predicate) | No |
| Sterilization | Eto (Same as predicate) | Eto |
2. Sample size used for the test set and the data provenance
The document mentions "Bench testing" and "Biocompatibility testing" but does not provide details on the sample sizes used for these tests. The data provenance is laboratory testing, not clinical data from patients.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This is not applicable as the study involves bench testing and biocompatibility, not clinical evaluation requiring expert ground truth for patient outcomes or diagnostic accuracy.
4. Adjudication method for the test set
Not applicable as it's not a clinical study with an adjudication process.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This device is a wound dressing, not an AI/ML diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a wound dressing, not an AI/ML algorithm.
7. The type of ground truth used
For the bench tests (vapor transmission, negative pressure maintenance, exudate removal), the "ground truth" would be the measured physical properties satisfying engineering specifications. For biocompatibility, the ground truth is adherence to ISO 10993 standards and accepted biological safety profiles for the materials. This is not "expert consensus, pathology, or outcomes data."
8. The sample size for the training set
Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established
Not applicable.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
January 11, 2019
Applied Tissue Technologies LLC % Michele Lucey Regulatory Affairs Manager Lakeshore Medical Device Consulting LLC 128 Blye Hill Landing Newbury, New Hampshire 03255
Re: K182409
Trade/Device Name: Applied Tissue Technologies PWD™ Platform Wound Dressing Regulation Number: 21 CFR 878.4780 Regulation Name: Powered Suction Pump Regulatory Class: Class II Product Code: OMP Dated: December 7, 2018 Received: December 12, 2018
Dear Michele Lucey:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Kimberly Ferlin -S
for Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K182409
Device Name
Applied Tissue Technologies PWD™ Platform Wound Dressing
Indications for Use (Describe)
The Applied Tissue Technologies PWD™ Platform Wound Dressing is intended to be used in conjunction with the Invia Motion Negative Pressure Wound Therapy (NPWT) system and is indicated in patients who would benefit from a suction device (NPWT) as it creates an environment that may promote wound healing by removing excess wound exudate. The Applied Tissue Technologies Platform Wound Dressing is appropriate for use on the following wounds: exudating, chronic, acute, traumatic, sub-acute and dehisced wounds, partial-thickness burns, ulcers (such as: diabetic, pressure and venous insufficiencies), flaps and grafts.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| ☑ Prescription Use (Part 21 CFR 801 Subpart D) | ☐ Over-The-Counter Use (21 CFR 801 Subpart C) |
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510(k) SUMMARY
Submitter Information
| Submitters' Name: | Applied Tissue Technologies LLC |
|---|---|
| Address: | 99 Derby Street, Suite 200Hingham, MA 02043 |
| Telephone: | 781-366-3848 |
| Contact Person: | Michele Lucey |
| Telephone: | 603-748-1374 |
| Date Prepared: | January 11, 2019 |
| Device Trade Name: | Applied Tissue TechnologiesPWD™ Platform Wound Dressing |
| Classification: | Class II |
| Product Code(s): | OMP |
| Regulation Number(s): | 21 CFR 878-4780 Powered Suction Pump |
| Predicate Device: | Medela Ag Invia Foam Dressing Kit,K170088 |
Intended Use:
The Applied Tissue Technologies PWD™ Platform Wound Dressing is intended to be used in conjunction with the Invia Motion Negative Pressure Wound Therapy (NPWT) system and is indicated in patients who would benefit from a suction device (NPWT) as it creates an environment that may promote wound healing by removing excess wound exudate. The Applied Tissue Technologies Platform Wound Dressing is appropriate for use on the following wounds: exudating, chronic, acute, traumatic, sub-acute and dehisced wounds, partial-thickness burns, ulcers (such as: diabetic, pressure and venous insufficiencies), flaps and grafts.
Device Description/Technological Characteristics:
The Applied Tissue Technologies PWD™ Platform Wound Dressing is a single use device. Its transparency permits the healthcare practitioner to observe the progress of the wound healing without removing the wound dressing. There is an access port to administer negative pressure wound therapy. The PWD is intended to be used for a maximum of 3 days. Therapy duration may be less than indicated if clinical practice or other factors require more frequent dressing changes.
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The PWD will be marketed in four different shapes and sizes, all having the same intended use. The four sizes are identified as follows.
| PWDTM Platform Wound Dressing | |
|---|---|
| Description | Catalog/REF # |
| 1" Round | AT1070-01 |
| 2" Round | AT1071-01 |
| 3" Round | AT1072-01 |
| 1" x 3" Oblong | AT1073-01 |
Performance Data:
Bench testing of the PWD™ Platform Wound Dressing was performed to evaluate device vapor transmission characteristics, ability to maintain negative pressure, and the ability to remove exudate. Biocompatibility testing was conducted according to the ISO 10993 standard series. Test results of all nonclinical testing were acceptable and demonstrate that the subject device is substantially equivalent to the predicate device
Substantial Equivalence:
The following chart provides the evidence to support the claim for substantial equivalence:
| Substantial Equivalence Comparison Chart | |||
|---|---|---|---|
| Feature / Specification | PWDTMPlatform WoundDressing | Invia Foam Dressing Kit(Medela Ag,) | Comparison |
| Regulatory Clearance/Approval Reference | K182409 | K170088 | N/A |
| Product Code | OMP | OMP | Same |
| Regulation Number | 21 CFR 878.4780 | 21 CFR 878.4780 | Same |
| Regulation Name | Powered Suction Pump(accessory) | Powered Suction Pump(accessory) | Same |
| Where used(environment) | The Negative PressureWound Therapy Systemis suitable for use in bothhospital and homecaresettings. | The Negative PressureWound Therapy System issuitable for use inboth hospital andhomecare settings. | Same |
| Maximum Duration ofa single dressing | 72 Hours | 72 Hours | Same |
| Negative Pressure tothe wound surfacerequirements in mmHg | 80 mmHg (nominal)+/- 20mmHG to thewound surface | 125 mmHg to the woundsurface | This constitutes anominalrecommendedsetting, pumpsettings rangefrom -40 to -175.This differencein recommendednominal setting. |
| Substantial Equivalence Comparison Chart | |||
| Feature / Specification | PWDTMPlatform WoundDressing | Invia Foam Dressing Kit(Medela Ag,) | Comparison |
| does not rangenew questions ofsafety. | |||
| Multiple Shapes forWound Sizes up to400cc (Surface Area xdepth) | 400cc | 240 - 2700c | PWD is withinthe range of thepredicatedevice. |
| DressingConfiguration | Clear polyurethaneembossed occlusive drapewith tubing | Clear polyurethaneocclusive drape dressingwith foam insert negativepressure/instillation tubing –dressing is cut to size | Similarmaterials andconfiguration,the PWD uses aembossed layerto allow forfluid transfer,the predicateuses afoam. Thisdifference doesnot raise newquestions ofsafety. |
| Access Port | For attachment to thenegative pressure pump.For removal of fluids. | For attachment to thenegative pressure pump.For removal of fluids | Same. |
| Collection Pack | The PWD tubing isconnected to the MedelaInvia Motioncanister/tubing set duringnegative pressure woundtherapy for collection offluids. The fluids areremoved from the woundsite and secured withinthe cannister. | The Invia Foam DressingTubing is connected to theMedela Invia Motioncanister/tubing set duringnegative pressure woundtherapy for collection offluids. The fluids areremoved from the woundsite and secured within thecannister | Same. |
| Pump | To be used with theMedela Invia®Motion™ NegativePressure WoundTherapy System | To be used with the MedelaInvia® Motion™ NegativePressure Wound TherapySystem | Same |
| How Supplied | PWD is Sterile SingleUse Only | Dressing is SterileSingle Use Only | Same |
| Substantial Equivalence Comparison Chart | |||
| Feature / Specification | PWDTMPlatform WoundDressing | Invia Foam Dressing Kit(Medela Ag,) | Comparison |
| Tissue ContactMaterials | Polymers and Adhesive | Polymers Adhesive anddressing | Similar,differences donot introducenew questions ofsafety |
| Additives - antimicrobial,animal origin | No | No | Same |
| Sterilization | Eto | Eto | Same |
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The PWD™ Platform Wound Dressing is substantially equivalent to the predicate device, the Invia Foam Dressing Kit (K170088) and does not raise different questions of safety and effectiveness.
§ 878.4780 Powered suction pump.
(a)
Identification. A powered suction pump is a portable, AC-powered or compressed air-powered device intended to be used to remove infectious materials from wounds or fluids from a patient's airway or respiratory support system. The device may be used during surgery in the operating room or at the patient's bedside. The device may include a microbial filter.(b)
Classification. Class II.